ER26-3515-000 · 2026-09-01 · Pennsylvania Public Utility Commission

Answer of the Pennsylvania Public Utility Commission in support of the Organization of PJM States, Inc.’s motion for extension of time to submit comments in response to PJM Interconnection, L.L.C.’s filing

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COMMONWEALTH OF PENNSYLVANIA 
 
PENNSYLVANIA PUBLIC UTILITY COMMISSION  
 
COMMONWEALTH KEYSTONE BUILDING  
400 NORTH STREET, THIRD FLOOR 
  
HARRISBURG, PENNSYLVANIA 17120  
  
 
September 1, 2026 
Via Electronic Filing  
The Honorable Debbie-Anne A. Reese, Secretary  
Federal Energy Regulatory Commission  
888 First Street, N.E.  
Washington, D.C.  20426  
 
Re:  
PJM Interconnection, L.L.C., Docket No. ER26-3515 
 
Dear Secretary Reese:  
 
Please find for e-filing the Answer of the Pennsylvania Public Utility Commission 
(PA PUC) in support of the Organization of PJM States, Inc.’s (OPSI) motion for 
extension of time to submit comments in response to PJM Interconnection, L.L.C.’s filing 
in the above-referenced docket.   
 
Copies of this document have been served upon all parties designated on the 
Commission’s official service list, in accordance with Rule 2010 of the 
Commission’s Rules of Practice and Procedure. 
 
If you have any questions, please do not hesitate to contact me.  
 
Respectfully submitted,  
  
/s/ Elizabeth H. Barnes 
Elizabeth H. Barnes  
Deputy Chief Counsel   
Pennsylvania Public Utility Commission  
(717)772-5408  
ebarnes@pa.gov

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UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
 
PJM Interconnection, L.L.C. 
Docket No. ER26-3515-000 
 
 
ANSWER OF THE PENNSYLVANIA PUBLIC UTILITY COMMISSION TO 
MOTION FOR EXTENSION OF TIME 
 
 
Pursuant to Rule 213 of the Federal Energy Regulatory Commission’s 
(“Commission”) Rules of Practice and Procedure, 18 C.F.R. § 385.213(a)(3), Intervenor 
Pennsylvania Public Utility Commission (PA PUC) submits this Answer in Support of 
the Motion of the Organization of PJM States (OPSI) for a two-week extension of time to 
submit comments in response to PJM’s August 13, 2026 filing proposing revisions to the 
Open Access Transmission Tariff (“Tariff”) and the Reliability Assurance Agreement 
Among Load Serving Entities (“RAA”) to establish Interim Resource Adequacy Service 
(“IRAS”), among other things.1  PA PUC supports and joins in OPSI’s request that the 
Commission extend the time for comments in this docket from September 3, 2026 to 
September 14, 2026.   
 
PJM proposes a compensation mechanism for new large loads (NLLs) that provide 
a load reduction service, i.e. curtailment, which creates new obligations for Electric 
Distributors. There is also an opportunity for NLLs to waive this compensation, and ways 
that states may be able to modify this compensation at the retail level. PA PUC also 
requests time to examine PJM’s filing and seek clarification regarding the complicated 
issue of how IRAS service may or should be compensated at the retail level.  We find 
some ambiguity due to discrepancies between PJM’s transmittal letter and the red-lined 
 
1 PJM Interconnection L.L.C., Proposal to Establish Interim Resource Adequacy Service and a Large 
Load Registry to Address System Reliability, Docket No. ER26-3515-000 (August 13, 2026) (“IRAS 
Filing”).

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tariff amendments proposed on this issue of 0-50% compensation.  PA PUC sees some 
potential jurisdictional conflicts arising from the proposed tariff amendments and may 
file comments as to what role States should have in controlling the compensation rate via 
state-level retail tariffs.   The curtailment protocol was not developed with PA PUC’s 
input, and it may impinge upon our jurisdiction over retail rates.  Specifically, PJM’s 
tariff redlines prescribe compensation obligations for Electric Distribution Companies. 
The redlines for Tariff section X.b.i. identify EDC compensation obligations and 
collection thereof from jurisdictional customers (See page 105 of PJM’s filing).  The 
tariff does not expressly recognize state authority to prohibit, approve, or modify such 
compensation and jurisdictional  recovery.  No party will be prejudiced should FERC 
grant OPSI’s motion, nor is the motion made solely for the purpose of delay.  It is in the 
public interest to grant OPSI and the PA PUC an additional two weeks to review the PJM 
filing and develop comments in response. 
 
CONCLUSION 
 
WHEREFORE, the Pennsylvania Public Utility Commission respectfully requests 
that the Commission grant OPSI’s motion and extend the deadline for answers to  PJM’s 
IRAS filing to the close of business on Monday, September 14, 2026. 
   
Respectfully Submitted,  
/s/ Elizabeth H. Barnes 
Elizabeth H. Barnes  
Deputy Chief Counsel   
Pennsylvania Public Utility Commission  
400 N. St., 3rd Foor 
Harrisburg, PA 17120 
(717)772-5408  
ebarnes@pa.gov

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CERTIFICATE OF SERVICE  
I HEREBY CERTIFY that I am on this date serving a copy of the foregoing comments 
upon each person designated on the official service list compiled by the Federal Energy 
Regulatory Commission in accordance with the requirements of Rule 2010 of the 
Commission’s Rules of Practice and Procedure. 
 
Respectfully submitted, 
 
/s/ Elizabeth H. Barnes 
Deputy Chief Counsel 
Counsel for the Pennsylvania 
Public Utility Commission 
P.O. Box 3265 
Harrisburg, PA  17105-3265 
Tel: (717) 787-5000 
 
Dated:  September 1, 2026